Welcome to the bimonthly publication IRS Insights, produced by Deloitte's Tax Controversy Services Group to keep our clients abreast of current issues related to the Internal Revenue Service. In this month's issue:
· IRS Identifies Circumstances Pursuant to which Disclosure on an Income Tax Return will be Adequate – The IRS issued its annual guidance in Rev. Proc. 2005-75 that sets forth the circumstances under which disclosure on an income tax return will be deemed adequate disclosure for purposes of avoiding the substantial understatement penalty set forth in section 6662(d) and the preparer penalty set forth in section 6694(a).
· Six-Month Automatic Extension for Individual Taxpayers and Certain Partnerships to File Their Income Tax Returns – The IRS has issued temporary regulations that simplify procedures for obtaining six-month extensions of time for filing certain returns. The regulations extend from four months to six months the period for which individuals may obtain an automatic extension of time to file their federal income tax returns. For certain partnerships, the automatic extension is increased from three months to six months.
· IRS Issues Guidance on Steps to Request Waivers from E-filing Requirements and Rejected E-Filed Returns – The IRS issued Notice 2005-88, which sets forth procedures that corporations, electing small business corporations and tax exempt organizations must follow to request a waiver of the requirement to electronically file Form 1120, Form 1120S, Form 990 and Form 990-PF.
· The Hurricane Relief Act Makes Certain Modifications to the Interest Suspension Rules – The Hurricane Relief Act expands the scope of the interest suspension rules to include amended returns and other similar documents. The Hurricane Relief Act also modifies the suspension of interest rules for certain reportable and listed transactions undertaken by individuals.
· Tax Controversy Update: IRS Guidance Expands Hurricane-Related Relief – In Notice 2005-81 and 2005-82, the IRS announced that it has expanded certain hurricane-related relief provisions with respect to Hurricanes Katrina and Rita.
· Recent Guidance
See attached file for details.
|
|
|
|
|
IRS Identifies Circumstances Pursuant to which Disclosure on an Income Tax Return will be Adequate
|
|